Demar Edwards v. County of Northampton, 663 F. App'x 132

Plaintiff Demar Edwards, a pretrial detainee, contracted a serious MRSA infection after ankle surgery while housed at Northampton County Prison and underwent multiple surgeries and prolonged treatment.
Edwards sued under 42 U.S.C. § 1983 (pro se), naming county officials/prison (Northampton defendants) and private medical providers/PrimeCare employees (medical defendants), alleging Eighth, First, and Fourteenth Amendment violations for filthy conditions, inadequate MRSA precautions, and deficient medical care.
District Court dismissed certain medical defendants for lack of alleged involvement, allowed amendments, and after discovery granted summary judgment for all defendants. Edwards appealed; the Third Circuit summarily affirmed.
The court evaluated conditions-of-confinement and medical-care claims under the Fourteenth Amendment for a pretrial detainee but applied the deliberate-indifference standard (analogous to Eighth Amendment jurisprudence).
The record showed inmate complaints about medical care but no evidence that county officials knew of or caused unclean cell conditions or that prison conditions caused the MRSA; medical records showed ongoing, responsive treatment by medical staff.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conditions of confinement (unclean cell caused MRSA)	Edwards: filthy cell and urine-soaked toilet caused or materially contributed to MRSA infection	Defendants: no notice to county officials and no causal link between cell conditions and infection	Summary judgment for defendants — no evidence officials knew of conditions or that conditions caused MRSA
Failure to implement/enforce MRSA precautions	Edwards: prison recklessly failed to implement adequate MRSA precautions	Defendants: Warden Buskirk had implemented enhanced MRSA measures in 2009 (sanitation expert, laundry upgrades, inspections)	Summary judgment for defendants — precautions had been enhanced and no deliberate indifference shown
Municipal/ supervisory liability (Northampton County and officials)	Edwards: county officials/customs/policies caused deprivation	Defendants: no policy/custom shown and individual officials lacked knowledge or involvement	Summary judgment for defendants — no Monell liability or individual deliberate indifference
Inadequate medical care / deliberate indifference	Edwards: medical defendants provided inadequate treatment, delayed care, or denied vital medical knowledge	Defendants: provided ongoing, tailored treatment; disagreements reflect medical judgment, not constitutional denial	Summary judgment for defendants — records show treatment and no deliberate indifference

Giles v. Kearney, 571 F.3d 318 (3d Cir.) (standard of appellate review for summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S.) (moving party’s burden on summary judgment)
Anderson v. Liberty Lobby, 477 U.S. 242 (U.S.) (standard for genuine dispute of material fact)
Matsushita Elec. Indus. Co. v. Zenith Radio, 475 U.S. 574 (U.S.) (no genuine issue when record could not lead rational jury to find for nonmovant)
Farmer v. Brennan, 511 U.S. 825 (U.S.) (deliberate indifference standard for prison conditions)
Bell v. Wolfish, 441 U.S. 520 (U.S.) (treatment of pretrial detainees under Due Process)
Estelle v. Gamble, 429 U.S. 97 (U.S.) (deliberate indifference to serious medical needs standard)
Monell v. Dep’t of Social Servs., 436 U.S. 658 (U.S.) (municipal liability under § 1983 requires policy or custom)
Rouse v. Plantier, 182 F.3d 192 (3d Cir.) (definition of deliberate indifference in medical context)
White v. Napoleon, 897 F.2d 103 (3d Cir.) (deliberate indifference requires persistent course of treatment despite pain and risk)
Colburn v. Upper Darby Twp., 946 F.2d 1017 (3d Cir.) (application of deliberate indifference concept to detainees)
Best v. Essex County, 986 F.2d 54 (3d Cir.) (causation requirements for conditions claims)
Spruill v. Gillis, 372 F.3d 218 (3d Cir.) (reluctance to second-guess medical judgments)